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Digital Product Passport in Furniture and Construction: In-Depth Guide to the Biggest Shift of the Decade

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Digital Product Passport in Furniture and Construction: In-Depth Guide to the Biggest Shift of the Decade
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Construction Digital Product Passport (DPP) and CPR‑2024: What Professionals Must Know

This article clarifies, with official sources, how the new EU Construction Products Regulation 2024 (CPR‑2024) affects manufacturers, architects, designers and market operators, and what the Construction Digital Product Passport (DPP) will require. It corrects common misconceptions and provides a practical, verified roadmap.

For extended reading and to stay up to date on this topic, consult:

CPR‑2024 at a glance: dates and scope

  • Entry into force: 7 Jan 2025. Date of application: 8 Jan 2026.
  • Products in scope: construction products (including used and remanufactured), key parts, and kits as defined in CPR‑2024.
  • DoPC (Declaration of Performance & Conformity): a single document combining declared performance and conformity with applicable product requirements.
  • AVS framework updated: includes AVS 3+ for environmental sustainability validations by Notified Bodies.

What the Construction DPP is — and is not

The Construction DPP is defined by CPR‑2024 but implemented through future Delegated Acts. It is a digital record linking a product (via a data carrier, e.g., QR) to mandatory information including the DoPC, instructions/safety info, technical documentation and identifiers. It is designed to be interoperable with the ESPR DPP framework.

Important: The DPP obligation for construction products begins only after the European Commission adopts the Delegated Acts establishing the Construction DPP system. Manufacturers must then provide DPPs within 18 months of those Acts entering into force. Until then, manufacturers must supply the DoPC electronically (or via website under specific conditions).

Reliable timeline (based on CPR‑2024)

  1. 8 Jan 2026: CPR‑2024 becomes applicable. New obligations apply where products are covered by harmonised technical specifications (hTS) adopted under CPR‑2024, or where a manufacturer seeks an ETA under CPR‑2024.
  2. Construction DPP: starts when Delegated Acts enter into force. Manufacturers then have 18 months to provide DPPs via the official system.
  3. Legacy standards: hENs under CPR‑2011 remain valid until replaced. DPP obligations do not apply to products solely under CPR‑2011 hENs until updated under CPR‑2024.

What information the Construction DPP will include (Article 76)

  • DoPC (Article 15): performance on essential characteristics + conformity with applicable product requirements.
  • General product information, instructions for use and safety information (Annex IV; Article 22(6)).
  • Technical documentation (Article 22(3)).
  • Specific labelling information (if applicable via Delegated Acts).
  • Unique identifiers and links via a data carrier (Article 18(2), Article 79).

Key obligations for manufacturers (when in scope)

  • Determine product type and apply the corresponding product category; maintain Factory Production Control (FPC).
  • Draw up DoPC before market placement; affix CE marking accordingly.
  • Provide general information, instructions for use and safety in required languages; label 'only for professional use' where applicable.
  • Ensure unique product‑type identification; batch or serial number where available.
  • After Delegated Acts: provide the DPP through the system within 18 months and link it to a data carrier.

Declared use vs intended use (new clarity)

CPR‑2024 differentiates between intended use (broad purpose in hTS/EAD) and declared use (the manufacturer’s specific application within that scope). This must be consistently reflected in documentation, labels and promotional materials.

Environmental sustainability declarations (phased)

  1. From date of application: declare environmental essential characteristics in Annex II points (a)–(d) in the DoPC (according to EN 15804, except specific heating products).
  2. +4 years: add Annex II Section 2 points (e)–(m).
  3. +6 years: add Annex II points (n)–(s).

Notified Bodies validate the environmental assessment under AVS 3+ (including input data, assumptions, software and initial inspection of company‑specific data).

Impact by role: brands, designers, developers

  • Manufacturers/brands: systematise data for DoPC and environmental declarations; prepare for DPP once Delegated Acts apply; ensure FPC and CE processes.
  • Designers/architects: gain access to objective, comparable performance and environmental data; ensure specifications align with declared and intended uses.
  • Developers/clients: better tender transparency, lifecycle insights and risk reduction through verified, machine‑readable documentation.

Step‑by‑step checklist to prepare now

  1. Audit current data: materials, performance tests, environmental calculations (EN 15804), instructions/safety, and supplier evidence.
  2. Close gaps: origin and composition, environmental indicators, repairability/reuse, certifications, language coverage.
  3. Systems readiness: ensure your PLM/ERP/CMS can store machine‑readable DoPC and future DPP fields; plan data carriers (QR, etc.).
  4. Train teams: legal/regulatory basics (CPR‑2024), technical documentation quality, and transparent product storytelling.
  5. Prepare visuals and collateral: datasheets and comparisons that reflect declared performance, environmental indicators and declared uses.

Common mistakes to avoid (corrected)

  1. Assuming the Construction DPP is already mandatory by a fixed year. It starts only after Delegated Acts enter into force, with an 18‑month window for manufacturers.
  2. Thinking PDFs alone are sufficient. You will need human‑ and machine‑readable documents and interoperable data (for DoPC and later for DPP).
  3. Leaving key fields blank (origin, environmental indicators, declared use). This triggers delays and compliance risks.
  4. Underestimating AVS 3+ validation. Prepare complete, auditable environmental data and validated software methods.
  5. Not planning access control and IP protection. The DPP system will enable tiered access while protecting sensitive information.

FAQs and clarifications

  • Is DPP already mandatory for construction products? Not until the Delegated Acts establish the system and the 18‑month manufacturer window elapses.
  • Do old hEN‑based products (CPR‑2011) need a DPP now? No. DPP obligations apply to products under hTS/ETAs adopted in the CPR‑2024 framework once the Acts are in force.
  • What about furniture or other sectors? They fall primarily under ESPR’s cross‑sector DPP. This article focuses on construction under CPR‑2024.

Conclusion: prepare now, implement on time

CPR‑2024 modernises the construction product framework: unifying performance and conformity in the DoPC, phasing‑in environmental declarations, and introducing a Construction DPP to enhance transparency and circularity. Use the current window to standardise data and systems so you can deliver compliant, verifiable and high‑quality documentation as soon as the Delegated Acts enter into force.

Sources: CPR‑2024 official guide and regulation text (Construction Products Europe; Regulation (EU) 2024/3110).